Compliance Verification Activity Report: CV2122-029 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2275
• Inspector 2738

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta
• Saskatchewan

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Related events:

• CV2021-068
• CV2021-510

Rationale and scope:

This inspection verified Enbridge's compliance to the Environmental Protection Program and other specific Operational-phase procedures related to environmental protection at aboveground facilities in Saskatchewan and Alberta. Primarily, pump stations and meter stations in SK were inspected along the Line 93 (operating pipeline which was constructed during the Line 3 replacement project).

Compliance tool(s) used:

• None

Facility details

Facilities:

• LANGBANK
• GLENAVON
• ROWATT
• STONY BEACH TAKEOFF
• HARDISTY
• CRAIK
• CACTUS LAKE

Facility Types

• Pipeline
• Meter station
• Pump station
• Terminal

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Enbridge Environmental Protection Program

Observations (no outstanding follow-up required)

Observation 1 - Aboveground facilities: Regina to Hardisty

Date & time of visit: 2021-07-20 10:30

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Surface Water Management Plan
• Vegetation
• Vegetation Control
• Housekeeping
• Waste Management
• Training and Documentation
• Permits/Approvals

Facility:

• LANGBANK (Facility)

Observations:

The Inspection Team visited the following facilities across Saskatchewan and Alberta. The focus was on pump stations, though one meter station and one terminal were also included in the inspection:

Langbank (pump station)
Glenavon (pump station)
Rowatt (pump station)
Stony Beach Take-off (meter station and tank storage)
Craik (pump station)
Cactus Lake (pump station)
Hardisty (terminal)
 
At each station, the Inspection team toured the facility and inspected within the general scope of environmental protection. The overarching intention was ‘spot checking’ Enbridge’s compliance in operations with the standards/procedures within its Environmental Protection Program (EPP). The observations below are grouped by theme and are representative of the ‘spot checking’ at all seven facilities visited:

General Housekeeping

• The facilities inspected were consistently tidy and well kept.  These sites were generally free of garbage; in the rare occasion garbage was observed Enbridge staff cleaned it up immediately and without being prompted from the Inspection team.
• All of the monitoring wells observed appeared to be in working order with caps and locks in place.
• Gravel covering the facilities was observed to be recently raked. Contouring of the sites appeared to be well managed in general by Enbridge staff, which minimized erosion and sedimentation risks and supported a tidy and well-kept appearance.
• Where observed, facility signage was noted to be in good condition.

• Hazardous materials storage buildings were inspected at all facilities visited. Secondary containment and appropriate labels were observed in all locations. Across all locations, hazardous materials storage buildings were tidy and well organized.
• Hazardous liquids waste storage tanks were inspected, including used oil, varsol and toluene tanks. In all instances spot checked, these waste oil tanks had secondary containment, appropriate labeling compliant with WHMIS, and appeared to be in good condition. The Inspection Team and Enbridge discussed maintenance of these tanks which Enbridge indicated includes testing of the interstitial space between the two layers of walls within the tanks. Tanks were free of drips and leaks, and surrounding areas were free of residual contamination, suggesting diligence of Enbridge personnel working in these areas.
• Contaminated soil bins and oily rag bins were spot checked at all locations. Waste was properly sorted in all instances observed. At the Hardisty Terminal, additional types of waste storage and sorting were inspected at three locations. Wood debris, cardboard, garbage, oily rags, scrap metal, batteries, aerosol cans, and contaminated soil bins were all observed to be properly sorted in bins for eventual removal.
• Compressed gases were consistently observed to be stored upright and secured with a chain.

• Various sump tank areas were viewed across the facilities inspected. Area managers demonstrated familiarity with Enbridge's procedures for sump sampling and general maintenance for sump tanks.
• Upon request, Enbridge promptly provided the records of inspection and maintenance for a sump tank in the Craik station (Line 13 sump tank, 2020 records). CER IOs requested and reviewed Work Orders for Inspecting and Testing double walled sump tank (completed 27 October 2020), Inspecting and Testing sump system semi-annual (completed 14 October 2020 and 13 January 2020).

• Stormwater ponds were inspected at numerous facilities. The Inspection team and Enbridge staff discussed the sampling programs, procedure for releasing stormwater via sluice gates and pumps, and wildlife management. Enbridge staff was observed to be aware of the details of their internal procedure, as well as which sites had provincial discharge permits and the details of those site specific permits (where applicable).
• Upon request, Enbridge provided the results from the stormwater sampling program at the Glenavon facility. In this particular scenario, Enbridge’s sampling program identified that total suspended solids were elevated (due to heavy rain) in the stormwater pond, which resulted in delaying the release. Three days later, the stormwater pond water was re-sampled, results for TSS confirmed to be below the guideline level, and the release of water was then initiated. This example demonstrated Enbridge staff implementing their stormwater management procedure effectively.
• Out-flow areas which the stormwater being released flows into were also inspected visually by IOs. The group discussed various scenarios including potential herbicide content within the stormwater itself, erosion in the out-flow area, and receptors of the stormwater release such as wetlands. No compliance issues noted. Enbridge was observed by the Inspection Team to be managing their stormwater ponds and releases effectively to manage the potential hazards posed by site-specific conditions.

• Barn swallows and cliff swallows have been living at two of the stations inspected, in particular (Langbank and Craik) so the Inspection Team had an opportunity to view and assess Enbridge’s implementation of the Wildlife Management aspect of the EPP. The Inspection Team and Enbridge staff discussed various aspects of the wildlife management the company has been conducting in order to protect the birds, as well as safety of workers and operational requirements.
• Mitigations being implemented which demonstrate compliance with Enbridge’s EPP include deterrents (e.g., netting, sloped metal shields in frequent nesting locations) and alternative housing (nesting structures with nest cups) which has been installed at various locations within the facilities inspected.

• The Inspection team ‘spot checked’ the implementation of Enbridge’s Potable Water Testing procedure throughout the inspection.  Enbridge staff demonstrated familiarity with the details of the company’s procedure, which includes testing of potable water on site annually (with the exception of sites which are on municipal water). 
• Upon request, Enbridge staff provided the results from potable water testing at a number of facilities in Saskatchewan from the 2020 sampling program. An example was shared/discussed from the Stony Beach Takeoff metering station, at which the 2020 results indicated elevated coliforms in the potable water being hauled into the building. Staff described the subsequent steps which occurred to investigate, clean and rectify the situation to ensure clean potable water are available for staff. This example demonstrated the potable water procedure ‘in action’ to protect worker safety at Enbridge facilities.

• Vegetation management was inspected at numerous facilities, visually, as well as in discussion with Enbridge staff on how the procedure is implemented. Across the stations ‘spot checked’, no noxious weeds were observed, line of sight was maintained, and no vegetation growth was perceived to be a potential fire hazard. 
• Enbridge staff shared that the first round of spraying for 2021 has been conducted in the early summer and that generally the stations are sprayed 2-3 times per year.
• The Inspection Team assessed the vegetation along the perimeter of the fence line at all facilities visited; no indication of over-spraying or evidence of herbicide migration off site was observed. Enbridge staff demonstrated thorough knowledge of the company’s procedures as well as industry best practices in herbicide application in the context of protecting the environment surrounding the facility.
• Upon request, Enbridge provided the specific chemicals being used as spray at Langbank station, as well as the provincial permit for the contractors the company has hired to conduct the herbicide application.  No non-compliances were noted by the CER IOs.

• The Inspection Team inquired about Environment staff conducting internal inspections of facilities. Staff described the frequency and the nature of the inspections. IOs requested an example of a recent inspection report conducted by Environment Staff.
• The example provided was for the Herschel station which was conducted in July 2021. The documentation provided demonstrates Enbridge’s management system proactively assessing potential hazards to the environment and compliance with standards and procedures. No non-compliances were noted by the CER IOs.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: